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  #1  
Old 03-22-2011, 01:59 AM
Pat Butler Pat Butler is offline
 
Join Date: Jan 2002
State: Illinois
Professional Status: Certified Residential Appraiser
Posts: 4,011
Default Relo AMCs

Still confused. The new rules for 1455.250 have 3 parts, a, b, and c. "a" and "b" pertain to AMCs who represent lenders, then "c" seems to be related to the other two parts, yet does not specifically mention financial institutions. So I guess that would pull in any AMC, including relo mgt companies ordering on behalf of their corporate clients?

The reason it's so confusing is that the entire section (a,b,c) seems to be identifying lenders, yet section "c", if read by itself, appears to pull in any sort of AMC. Very poorly worded.
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  #2  
Old 03-22-2011, 06:55 PM
Brian Weaver Brian Weaver is offline
 
Join Date: Apr 2005
Location: Chicago area
State: Illinois
Professional Status: Gvmt Agency, FNMA, HUD, VA etc.
Posts: 2,516
Default

Quote:
Originally Posted by Pat Butler View Post
Still confused. The new rules for 1455.250 have 3 parts, a, b, and c. "a" and "b" pertain to AMCs who represent lenders, then "c" seems to be related to the other two parts, yet does not specifically mention financial institutions. So I guess that would pull in any AMC, including relo mgt companies ordering on behalf of their corporate clients?

The reason it's so confusing is that the entire section (a,b,c) seems to be identifying lenders, yet section "c", if read by itself, appears to pull in any sort of AMC. Very poorly worded.
Then I guess you should've said something when the Rules were open for public comment for 90 days. Here's the thing...nobody showed any interest in this prior to it becoming law. So, everyone takes that to be tacit approval of the language. No response is a response when crafting law.
  #3  
Old 03-22-2011, 09:56 PM
Pat Butler Pat Butler is offline
 
Join Date: Jan 2002
State: Illinois
Professional Status: Certified Residential Appraiser
Posts: 4,011
Default

I learned a long time ago that it is useless to try and get involved in appraisal law making here in Illinois. I once asked TJ about the process for getting considered for a vacant board postion and he replied by saying "We've gotten that taken care of." He didn't realize that I was looking for a response in his capacity as a board member, not the AI. He apparenly can't keep track of his various conflicts of interest. The lawmaking process is tightly controlled by a small group of people who run their own cabal and don't let outsiders have any influence. The trifecta of the AI, ICAP, and state board is inpenetrable. That's why the overwhelming majority of appraisers are smart enough to not join either the AI or IFA. Anyone who has been around long enough has the gig figured out. The same people just rotate through the various positions in the three groups.

There are far too many new laws that affect all us and it would be a full time job keeping track of them. I do stay involved in a number of other areas of my family's life where important legislation has a more profound effect, but there are only so many hours in the day that keep up with all the details.

I pay money to ICAP to supposedly look out for the interests of appraisers but I'm not ignorant as to what their goals are. We also pay some of the highest fees in the country for our license for which there should be an expectation that competent people are drafting these laws and regulations.

Unfortunately, the people actually on the receiving end of our money have falling down on the job and now we are apparently supposed to be doing their job too.

So now we are stuck with some new laws that are apparently "Final" and "Interim" as the same time and for which the law says there are enforcement capabilities and for which you say there aren't any yet. And we now have a pseudo AMC law for which it is obvious the no one considered the possibility of a relocation management company being involved in a transaction, and for which there is further confusion. And the same rule requires that we prominently insert specific language into the certification. Do the writers of these regs realize the majority of certification statements contained in form filling software are not editable? Furthermore, there are plenty of other requirements for the appraiser to prominently mention thing in the report. At what point is it no longer "prominently" displayed because it is competing with other text that is also suppose to be prominently displayed? Of course, we can all pay more money to ICAP to explain how these new laws work.

Last edited by Pat Butler : 03-22-2011 at 10:13 PM.
  #4  
Old 03-23-2011, 12:14 AM
leelansford leelansford is offline
 
Join Date: Mar 2002
State: Illinois
Professional Status: Certified Residential Appraiser
Posts: 13,700
Default

Quote:
Originally Posted by Pat Butler View Post
Still confused. The new rules for 1455.250 have 3 parts, a, b, and c. "a" and "b" pertain to AMCs who represent lenders, then "c" seems to be related to the other two parts, yet does not specifically mention financial institutions. So I guess that would pull in any AMC, including relo mgt companies ordering on behalf of their corporate clients?

The reason it's so confusing is that the entire section (a,b,c) seems to be identifying lenders, yet section "c", if read by itself, appears to pull in any sort of AMC. Very poorly worded.

Pat-

RE: 1455.250, a): "An appraiser shall identify an appraisal management company as the client if the appraisal management company is engaging the appraiser." Period. This is a stand-alone directive.

And, if the prospective AMC legislation comes about as written (SEE e-mail alert of Feb. 10th from ICAP to ICAP membership)...and specific to registration as an AMC:

"Section 15. Exemptions. Nothing is the Act shall apply to any of the following:...(2) a corporate relocation company..."

-Lee

A card-carrying member of the evil cabal .
__________________
Lee Lansford, IFA
"My opinions & my opinions only!"

Last edited by leelansford : 03-23-2011 at 12:28 AM.
  #5  
Old 03-23-2011, 12:26 AM
leelansford leelansford is offline
 
Join Date: Mar 2002
State: Illinois
Professional Status: Certified Residential Appraiser
Posts: 13,700
Default

Quote:
Originally Posted by Pat Butler View Post
... And the same rule requires that we prominently insert specific language into the certification. Do the writers of these regs realize the majority of certification statements contained in form filling software are not editable? ...

To answer the question, "yes".

Just as USPAP requires (when it comes to significant assistance) the "appraiser...state the name(s) of those providing...significant real property appraisal assistance in the certification...", there is understanding that "form-world" does not allow for this little nicety.

If I were communicating an appraisal on, say, a Fannie form and I had utilized "significant...assistance", I would be most certain to reference this prominantly ("disclose, disclose, disclose") within the report of the appraisal.
__________________
Lee Lansford, IFA
"My opinions & my opinions only!"
  #6  
Old 03-23-2011, 10:05 AM
leelansford leelansford is offline
 
Join Date: Mar 2002
State: Illinois
Professional Status: Certified Residential Appraiser
Posts: 13,700
Default

Quote:
Originally Posted by Pat Butler View Post

I learned a long time ago that it is useless to try and get involved in appraisal law making here in Illinois.

(RE...the process for getting considered for a vacant board postion

Self-nominating forms are available (you may have to do a bit of hunting, but, the form is there) at the IDFPR website.

At the moment, all 10 positions are filled...but no one lasts forever.
__________________
Lee Lansford, IFA
"My opinions & my opinions only!"
  #7  
Old 04-19-2011, 09:37 PM
Jim Onderisin Jim Onderisin is offline
 
Join Date: Sep 2003
Location: Du Page County, Illinois
State: Illinois
Professional Status: Certified Residential Appraiser
Posts: 2,847
Default

Quote:
Originally Posted by Pat Butler View Post
Still confused. The new rules for 1455.250 have 3 parts, a, b, and c. "a" and "b" pertain to AMCs who represent lenders, then "c" seems to be related to the other two parts, yet does not specifically mention financial institutions. So I guess that would pull in any AMC, including relo mgt companies ordering on behalf of their corporate clients?

The reason it's so confusing is that the entire section (a,b,c) seems to be identifying lenders, yet section "c", if read by itself, appears to pull in any sort of AMC. Very poorly worded.
It's a good thing we get the rules' meaning. Maybe a rewrite for your reports' "certification" sections would be in order.
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